What is the European Accessibility Act?
The European Accessibility Act is the EU law that, since 28 June 2025, requires many private digital services to be usable by everyone, not just the public sector as before. This guide covers what the directive is, which businesses it applies to, what the requirements mean in practice, and how to find out whether your site needs work.
By Simon Torngren · Partner and COO· Published · Updated Our view
The directive makes accessibility a requirement, not an opinion. But what the law asks for is largely the same thing that makes a site better for everyone: clear structure, code that assistive technology understands, forms people can actually fill in. Treat compliance as quality with a deadline, not a burden on the side.
What the Accessibility Act is.
The Accessibility Act is EU Directive 2019/882, often called the European Accessibility Act. In Sweden it applies through the Act on the Accessibility of Certain Products and Services and its ordinance. The aim is for digital products and services to be usable by people with disabilities, with the same requirements across the EU.
The big shift is who it covers. The public sector in Sweden has been covered for some time by DOS-lagen: government agencies and municipalities must meet accessibility requirements, with DIGG as the supervisory authority. The Accessibility Act moves much of the private sector under similar requirements. So this is not about what accessibility is, that is covered by the companion page on web accessibility, but about what the law requires and of whom.
In short, accessibility has gone from a recommendation for most companies to a legal requirement for many. For most, the question is no longer whether they should, but whether they are covered.
Who it applies to.
The directive covers a range of consumer-facing products and digital services. The most common ones for Swedish companies are:
- E-commerce. Online stores and checkout flows selling goods or services to consumers.
- Banking services. Online banking, payment services and similar consumer services.
- Electronic communication. Telephony, messaging services and video calls.
- Passenger transport. Websites, apps and e-tickets for travel.
- Media services and e-books. Streaming, programme guides and digital books.
- Terminals and equipment. ATMs and ticket machines, plus equipment such as routers, smartphones and e-readers.
There is an important exemption for microenterprises providing services: companies with under EUR 2 million in turnover and fewer than ten employees are exempt from the service requirements, but only partly from the product requirements. If you are unsure whether you are covered, the first step is to settle exactly that, as it defines your whole situation. This is an overview, not legal advice.
What the requirements mean.
The requirements are made concrete in the European standard EN 301 549. Its web part builds on WCAG level AA, the same target level that already applies to the public sector. In practice, a service should be perceivable, operable, understandable and robust: sufficient contrast, alternative text on images, keyboard navigation, clear structure and forms that can be completed with assistive technology.
How WCAG and the four principles work in detail is covered by the web accessibility page. Here it is enough to know that the directive does not invent its own technical requirements, it points to an established standard. If your site meets WCAG level AA, you are well on your way. Beyond the service itself, businesses also need to be able to show how the requirements are met.
That makes the work concrete and measurable: there is a standard to audit against, not a matter of interpretation. How Memorise works with web if you want the site built or audited against the requirement level.
Deadline, enforcement and sanctions.
The directive took effect on 28 June 2025. For services there is a transitional rule: contracts signed before that date may continue for up to five years, but new and changed services are covered immediately. For most of what is built today, the deadline has therefore already passed.
In Sweden, PTS, the Swedish Post and Telecom Authority, supervises the digital parts. Where there are shortcomings, the authority can require correction and, ultimately, decide on penalty fees or ban a product from being sold on the market. Because the rules are shared across the EU, the consequence can also be lost access to other EU markets, not just the Swedish one.
The practical takeaway is that waiting gets more expensive, not less. Fixing a site under supervision and time pressure costs more than doing it in a planned way.
How to find out where you stand.
The path to meeting the requirements is rarely a single big rebuild. It usually looks like this:
- 01Work out whether you are covered. Sector, service and company size decide, and this step saves the most time because it sets the frame for everything else.
- 02Audit the site against EN 301 549 and WCAG level AA. A review shows where the service shuts users out and what counts as an actual legal shortcoming.
- 03Fix by priority. Most issues are common and well known: contrast, alternative text, keyboard navigation, forms. Take what shuts out the most people first.
- 04Maintain and document. Accessibility is not a one-off, it has to be kept alive as the site changes, and businesses need to be able to show how the requirements are met.
Most of this overlaps with things that make the site better anyway: clearer structure, faster code, forms more people can use. Send us your web address and we will do a high-level review against the requirement level.
Are you covered by the Accessibility Act?
Send us your web address, and we will do a high-level review: whether your business is likely covered, where the site falls short of WCAG level AA, and what is easiest to fix first. You get a concrete picture to prioritize from, not a sales pitch.
Write to us →Frequently asked questions about the Accessibility Act
What is the European Accessibility Act?
The Accessibility Act is EU Directive 2019/882, implemented in Sweden through the Act on the Accessibility of Certain Products and Services. Since 28 June 2025 it requires many private digital products and services to be usable by people with disabilities, with the same rules across the EU. Previously, equivalent requirements applied mainly to the public sector.
Who is covered by the Accessibility Act?
Among others, e-commerce, banking services, electronic communication, passenger transport, media services, e-books and various terminals and equipment. Microenterprises providing services, with under EUR 2 million in turnover and fewer than ten employees, are exempt from the service requirements. Exactly what applies depends on sector and service, so the first step is to work out whether your particular business is covered.
When did the Accessibility Act take effect?
On 28 June 2025. For services there is a transitional rule: contracts signed before that date may continue for up to five years, but new and changed services are covered immediately. For most of what is built today, the deadline has therefore already passed.
Are small companies covered?
Microenterprises providing services, defined as under EUR 2 million in turnover and fewer than ten employees, are exempt from the service requirements but only partly from the product requirements. Other small and medium-sized companies may well be covered. Size alone does not decide, the combination of sector, service and company size does.
What happens if we don't comply?
In Sweden, PTS supervises the digital parts. Where there are shortcomings, the authority can require correction and, ultimately, decide on penalty fees or ban a product from being sold. Because the rules are shared across the EU, the result can also be lost access to other EU markets. Beyond that there is the business risk: customers who cannot use the service.
How does it differ from DOS-lagen?
DOS-lagen covers the public sector: the websites of government agencies and municipalities, with DIGG as the supervisory authority. The Accessibility Act extends similar requirements to the private sector. The technical target level is essentially the same, WCAG level AA via the EN 301 549 standard, but what changes is who is covered.